Total Invoice Price/Rebates

In the special circumstances in which Medicare Parts A and B reimburse a provider's total invoice price:

total invoice price is defined as the net amount a provider pays for an item/service, taking into account ALL discounts, rebates, refunds, or other adjustments.

It therefore is the provider's obligation under Medicare Parts A and B to report and return any third-party amount received for an item/service after the provider has billed and received Medicare reimbursement for that item/service - whether that additional amount is in the form of a discount, rebate, refund, or other adjustment.

A common example would be a provider reporting and billing Medicare for total invoice price on an item/service resulting in Medicare payment, only to receive volume-based rebate dollars after Medicare's payment. These additional rebate dollars, not accounted for in the original total invoice price billed because the amount was not then known, are considered by Medicare to be an "overpayment."

It is the provider's obligation to report all overpayments and voluntarily refund the overbilled amount.

Noridian provides opportunities for provider self-disclosure and return of overpayments via Part B Non-MSP Voluntary Checks form (access under 'Overpayment/Recoupment' forms).

To return an overpayment, the provider must:

  1. Include on the Form the beneficiary's name and ICN number found on the claim that received the overpayment
  2. Select Reason Code for Claim Adjustment-#14 (Other)
  3. In the "Other" box, include the following information per claim: Rebate- CPT/HCPCs Code XXXXX; Original Invoice Price $XXX; Corrected Invoice Price $XXX; refund $XXX

If the return of an overpayment involves multiple beneficiaries, the provider may utilize the Non-MSP Voluntary Refund Spreadsheet for reporting. (access under 'Overpayment/Recoupment' forms). Follow the procedure above for the Part B Non-MSP Voluntary Checks Form.

In summary, Noridian understands that the return of overpayments may be an added burden for providers. However, neither the timing of a rebate nor the form or type of rebate or discount program in which the rebate is presented changes Medicare's expectation that the rebate must be passed on to the Medicare program.

It is ultimately up to the provider to determine whether to participate in a rebate program and thus accept any related regulatory obligations (including the return of any amount due its Medicare patients).

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